GSA and DHA recently announced they were partnering to add a new health IT Special Item Number (SIN) to Schedule 70, the largest acquisition vehicle for IT products and services with over $14 billion in annual sales. This is in direct response to an increase in health IT spending: over $30 billion was spent in 2015 and it’s projected to grow at an annual rate of 7.4 percent.
A draft solicitation will be released on or around April 22, and the final solicitation is expected to be released on or around May 30. If you’re a health IT vendor, you should consider adding this new SIN since it provides government customers a more direct, centralized and streamlined gateway to procuring health IT products and services.
We sat down with Melody Giangreco Smith, Executive Contracts Manager at Federal Schedules Inc. (FEDSched), an employee-owned small business specializing in all aspects of GSA Schedule Contract acquisition, management and compliance. FEDSched has been helping companies obtain and manage their GSA Schedule Contracts since 1986. Black Branch has worked closely with the company for many years, recently helping a client navigate this often complex undertaking to secure their Schedule 70 in only 3 months—from scratch.
Melody shares her thoughts on the new health IT SIN’s benefits and how companies can prepare for its release. Read on for her insights and also check out our handy reference sheet.
Can you give an overview of the new GSA health IT SIN?
For companies with expertise in health IT, the GSA IT Schedule 70 health IT SIN represents an avenue for streamlining government procurements at the federal and state/local level. It is a dedicated category that agencies may use to purchase health IT solutions from pre-vetted businesses with pre-negotiated pricing, terms and conditions.
Why do you think GSA is creating the health IT SIN?
There is an increasing call across the federal government to eliminate duplicative contract vehicles and reduce redundancies. Federal News Radio recently wrote an article detailing the Office of Federal Procurement Policy’s plans to strengthen existing guidance aimed at reducing the number of multiple award contracts.
This move to reduce duplicative contracts is one of the driving reasons behind DHA’s collaboration with GSA. One of GSA’s core elements is to serve as the buying arm of the federal government. Individual agencies don’t typically possess the level of expertise needed to administer many of the contract vehicles they seek to establish.
GSA is also consistently looking to increase the market share of federal spending through the GSA Schedules program, with efforts being amplified over the past few years in particular. About a year ago Federal Times reported Tom Sharpe stated a goal of increasing GSA’s market share to 33% of federal spending over the next 3 years. Tapping into the $30 billion health IT industry represents a path to reach this goal, and a dedicated health IT SIN will facilitate the effort. With Schedule 70’s existing structure, federal buyers are unable to identify health IT-specific solutions. The new health IT SIN allows them to carve out and identify the experts within the healthcare market. As an added benefit, the dedicated SIN allows GSA to track spending on a more granular level.
Will the new health IT SIN change how agencies approach health IT acquisition strategies?
Anytime you are procuring through a pre-negotiated contract vehicle, the overarching desire is to find the most sustainable and efficient procurement mechanism. Acquisitions through the GSA Schedule contract are governed by FAR Subpart 8.4, which is designed to significantly simplify the procurement process.
Can you briefly describe the process for a company to add this new health IT SIN?
If your company doesn’t already hold a GSA IT Schedule 70 Contract, you should look at beginning the process now, as opposed to waiting for the health IT SIN to be released–provided you currently qualify. At the very minimum, your company must provide 2 years of stable financials and past performance within one of the existing SINs detailed or the Schedule 70 Solicitation on GSA eLibrary. We provide a high-level overview of the steps involved in obtaining a GSA Schedule Contract here.
If your company only provides health IT, you will have to pursue an alternate SIN. Depending upon your specific offering, health IT can currently be placed under SIN 132-8 IT Equipment, SIN 132-51 IT Professional Services or SINs 132-32/33 Software License.
From submission of your proposal, it could take 3-4 months to receive a GSA IT Schedule 70 Contract award. With the health IT SIN expected to roll out in May of this year, it should be available by the time your contract is awarded. Once awarded, you will have the ability to modify your contract to add additional products and service offerings, including those under the health IT SIN.
If your company already holds a GSA IT Schedule 70 Contract, you will be able to submit a modification to add the health IT SIN to your contract when GSA issues the solicitation refresh with the new SIN details.
While we won’t know the final health IT SIN requirements until GSA issues the IT Solicitation refresh, companies can start preparing based upon: 1) what is typically required for a modification to add a SIN and 2) what will most likely be required based upon information released, such as the recent industry day and Requests for Information (RFIs).
The Standard Modification Process
Certain documentation is required across the board for modifications involving the addition of labor categories. This includes a certification letter, past performance, labor category descriptions, technical requirements as defined by the Solicitation, and pricing support.
All GSA Contract modifications are submitted electronically through GSA’s eMod system and require the user to hold a digital certificate. Once submitted, your GSA Contracting Officer will review your modification request against criteria detailed in the GSA Schedule Solicitation.
What May Be Required
Based upon information currently available, companies will have to demonstrate expertise and past performance in the health IT industry.
Companies offering EMR products must be Office of the National Coordinator (ONC) health IT certified and all companies must comply with commercial health IT standards, as well as accepted industry and federal agency guidelines, including:
- ONC Health IT Interoperability Roadmap
- Federal Health IT Strategic Plan
- Health IT for Economic and Clinical Health (HITECH) Act
- The Health Insurance Portability & Accountability Act of 1996 (HIPAA) Privacy Rule
- The FDA Safety & Innovation Act of 2012 (FDASIA)
- The Affordable Care Act (ACA)
- FDA regulations for medical devices
- 2015 Edition Heath IT Certification Criteria
- HHS regulations for the meaningful use of electronic health record technology
- Medicare Access and CHIP Reauthorization ACT (MACRA)
What is the typical turnaround time for a modification such as the health IT SIN?
Companies commonly underestimate time expectations and support requirements, including proof of expertise. If the modification represents a true area of expertise, your company may spend a few hours to a week on modification prep.
Generally speaking, modifications are then processed within 35-40 days. The processing time may be extended if the modification requires a review of any license agreement or other technical review process.
What is the advantage to getting yours done as soon as the new SIN is released?
Considering DHA’s significant interest in using the GSA Schedules for procurement and the potential market share, companies will be best served by being at the gate as soon as possible and securing the ability to compete on expected task orders.
One final note on the health IT SIN – sometimes evaluation criteria/requirements can be so stringent that they create an entry barrier for companies. This can arguably be the case with the recent implementation of the Schedule 70 cloud computing services SIN. It is important that GSA finds a good balance that allows access for experienced and truly qualified businesses.
Do you have experience adding a modification or have any questions about the upcoming health IT SIN? Let us know in the comments.
About the Author: Melody Smith is the executive contracts manager at Federal Schedules Inc. She has over eighteen years of extensive experience across all of the GSA Schedules including, but not limited to the GSA IT-70, Professional Services Schedule (PSS), and Human Resources and EEO Services Schedule Solicitations. She is a frequent speaker on federal contracting and member of the National Contract Management Association (NCMA).